On page 12 of her court document, I read this paragraph which was interesting:
Furthermore, the government has acknowledged the involvement of at least one other individual in the management of PM&A [Pamela Martin & Associates] during the relevant time period who is not subject to prosecution. See Opp. at 27 ("[T]here was the period from April 29, 2002 until November 12, 2002 [] when another woman with the supervision of defendant, ran [PM&A]."). If it is Ms. Palfrey's conduct in the leadership role of PM&A which has led to her being the target of this Indictment, the government's failure to charge this other individual, who occupied substantially the same leadership role, suggests that its stated motive may simply be pretext for an improper one.9
9 In correspondence with the government, Ms. Palfrey, through counsel, requested information on this point as part of discovery required by Brady v. Maryland, 373 U.S. 83 (1963), and Giglio v. United States, 405 U.S. 150 (1972). Specifically, defense counsel notified the government that it considered subject to discovery any non-prosecution decisions, immunizations, or other disposition arrangements regarding the independent contractors utilized by PM&A who the government alleges engaged in prostitution services. To date, the government has provided no such information. The government has indicated that the Giglio discovery will be turned over "in time for defendant's to make use of it," and the Jencks material will be provided one week before trial. Counsel for Ms. Palfrey disagrees strongly with this timetable and position
Here is the court document:
The real question is who is the another employee at PM &A who worked with Ms. Palfrey in the same leadership role as Ms. Palfrey and why wasn't the person equally charged or subject to prostitution charges?
Furthermore, the government has acknowledged the involvement of at least one other individual in the management of PM&A [Pamela Martin & Associates] during the relevant time period who is not subject to prosecution. See Opp. at 27 ("[T]here was the period from April 29, 2002 until November 12, 2002 [] when another woman with the supervision of defendant, ran [PM&A]."). If it is Ms. Palfrey's conduct in the leadership role of PM&A which has led to her being the target of this Indictment, the government's failure to charge this other individual, who occupied substantially the same leadership role, suggests that its stated motive may simply be pretext for an improper one.9
9 In correspondence with the government, Ms. Palfrey, through counsel, requested information on this point as part of discovery required by Brady v. Maryland, 373 U.S. 83 (1963), and Giglio v. United States, 405 U.S. 150 (1972). Specifically, defense counsel notified the government that it considered subject to discovery any non-prosecution decisions, immunizations, or other disposition arrangements regarding the independent contractors utilized by PM&A who the government alleges engaged in prostitution services. To date, the government has provided no such information. The government has indicated that the Giglio discovery will be turned over "in time for defendant's to make use of it," and the Jencks material will be provided one week before trial. Counsel for Ms. Palfrey disagrees strongly with this timetable and position
Here is the court document:
The real question is who is the another employee at PM &A who worked with Ms. Palfrey in the same leadership role as Ms. Palfrey and why wasn't the person equally charged or subject to prostitution charges?
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